Privacy policy

Privacy policy

Oclaner Asset Management Pte. Ltd. (“Oclaner AM”) recognizes the importance and sensitivity of Personal Data and is fully committed to protecting the privacy interests of individuals who provide confidential information to Oclaner AM, as we consider privacy to be a fundamental aspect of our relationship with our clients, service providers and business associates.

As required under the Singapore Personal Data Protection Act (“PDPA”) of Singapore, this policy is to inform you how Oclaner AM manages Personal Data (as defined below).

By interacting and corresponding with Oclaner AM (via electronic means, telephone or face-to-face meetings), accessing and using Oclaner AM’s website, submitting information to Oclaner AM, or signing up for any products or services offered by Oclaner AM, you agree and consent to Oclaner AM collecting, using and disclosing and sharing your Personal Data to Oclaner AM’s authorised service providers and relevant third parties in the manner contemplated in this Data Protection Policy.

This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to Oclaner AM in respect of your Personal Data, and your consents are additional to any rights which Oclaner AM may have at law to collect, use and disclose your Personal Data.

Oclaner AM may from time to time update this Data Protection Policy to ensure compliance and consistency with any future developments or changes in legal or regulatory requirements. By continuing to engage Oclaner AM’s services, to use Oclaner AM’s website (www.oclaner.com) or communicate with Oclaner AM subsequent to any updates, you agree to be bound by the updates to this Data Protection Policy.

Personal Data

Personal Data” refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which the organisation has or is likely to have access. This includes data and information in Oclaner AM’s records as may be updated from time to time.

Some examples of Personal Data may include your name or your company name; date of birth; country of birth; NRIC or passport or other identification numbers and documents; signatures; employment details, information relating to your financial circumstances; contact details such as addresses, email addresses, telephone and facsimile numbers; and any other information relating to any individuals which you may have provided to Oclaner AM or documents and/or agreements you may have signed with Oclaner AM.

Collection of Personal Data

Personal data may be collected by Oclaner AM in the following ways:

  • When you submit any forms to Oclaner AM during the course of our relationship;
  • When you enter into any agreement or provide other forms of documentation or information to Oclaner AM in respect of or in connection with engaging or utilizing Oclaner AM’s services, or collaborating with Oclaner AM;
  • When you interact with employees of Oclaner AM via telephone calls, letters, facsimile, face-to-face meetings and other electronic means;
  • When you respond to Oclaner AM’s request for additional Personal Data; and/or
  • When you submit your Personal Data to Oclaner AM for any other reason.

If you provide Oclaner AM with any Personal Data relating to a third party (e.g. information on your spouse, children, parents, and/or employees), you represent to Oclaner AM that you have obtained the necessary consent of such third party to you providing Oclaner AM with their Personal Data for the respective purposes. You should ensure that all Personal Data is complete, accurate, true and correct.

When you browse Oclaner AM’s website, you generally do so anonymously. Oclaner AM does not automatically collect Personal Data.

Use of Personal Data

Oclaner AM collects, uses and discloses your Personal Data for the following purposes:

  • Verifying your identity;
  • Assessing and processing any applications or requests made by you for products and services offered by Oclaner AM;
  • Responding to your queries and requests and handling complaints;
  • Managing and facilitating the administrative and business operations of Oclaner AM and complying with internal policies and procedures (including financial reporting, regulatory reporting, management reporting, risk management, audit and record keeping purposes);
  • Complying with applicable anti-money laundering, tax evasion and anti-terrorist financing laws, regulations and rules;
  • Complying with any legal, governmental or regulatory requirements, codes of practice or guidelines of any relevant jurisdiction;
  • Complying with the requirements or directions of any competent regulatory authority;
  • Providing client-related services including dissemination of notices and reports; and
  • Any other purpose relating to any of the above.

Oclaner AM may have also specifically notified you of any other purposes which Oclaner AM collects, uses or discloses your Personal Data in relation to specific services or in your dealings with Oclaner AM. By doing so, you agree and consent to Oclaner AM collecting, using and disclosing your Personal Data for these additional purposes as well.

Disclosure of Personal Data

Subject to the provisions of any applicable law, Oclaner AM may be required to disclose your Personal Data for the purposes listed above (where applicable), to the following third parties located in Singapore or overseas:

  • Oclaner AM’s service providers involved in providing, managing or administering services provided to you;
  • External banks and financial institutions and their service providers in relation to asset management and investment product settlement processing;
  • Oclaner AM’s professional advisors;
  • Relevant government regulators, statutory bodies or authorities and/or law enforcement agencies;
  • Your authorised representatives; or
  • Any other party to whom you authorize Oclaner AM to disclose your Personal Data to.

Data Security

Oclaner AM will take reasonable efforts to protect your Personal Data from loss, misuse and unauthorized disclosure. Oclaner AM restricts access to information about you to its employees on a need to know basis. To protect information about you, Oclaner AM maintains physical, electronic and procedural safeguards according to industry standards and practices which are reviewed on a regular basis. Oclaner AM retains your Personal Data to the extent one or more of the purposes for which it was collected remain valid and for other legal or business purposes which retention may be necessary.

While Oclaner AM strives to protect your Personal Data, Oclaner AM cannot completely guarantee the security of the information transmitted to Oclaner AM as no data security measures can guarantee 100% security at all times.

Data Access and Data Correction

If you:

  • would like to obtain access to your Personal Data;
  • would like for your Personal Data to be corrected or updated; or
  • would like to withdraw your consent or limit the use of your Personal Data,

You may submit your written request to:
Attn: Head of Legal & Compliance
Oclaner Asset Management Pte Ltd
One Temasek Avenue
#37-04/05 Millenia Tower
Singapore 039192

Please note that Oclaner AM reserves the right to refuse your requests for any reasons permitted by law. Where permitted by law, you may ask that Oclaner AM collect or delete any inaccurate information.

If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, may result in Oclaner AM not being in a position to communicate or correspond with you, to continue providing services to you, or to administer any contractual relationship already in place.

Governing Law

This Data Protection Policy shall be governed by and construed in accordance with the laws of Singapore.